Document ZnwaxQq32gOyGxNo807Y327jO

FILE NAME: Union Carbide (UC) DATE: 0000 DOC#: UC047 DOCUMENT DESCRIPTION: Internal Report - OSHA Standards and the Safe Use of Asbestos Trot) FILED CSMA STANDARDS AND THE SAFE USE OF M nCtTOt 4OTHI haWJW - IM m CmMAbCwf* Asbestos is one of the first target hazards to be handled by the Occupational Safety and Health Agency of the U.S. Department of Labor. The unique properties of asbestos, a fibrous mineral, have resulted in its use in over 3000 applications. There is no reason to prohibit the use of enrysotile asbestos as fiber concentrations in the vork~ place and in the general environment can be readily and satisfactorily controlled. ! si vr a * . * . e weiffc especially ter I t p0?8 "itaet of th media treatment * ; . "" ' `i V i ' L S U i i n ! oi' w t ! m , ! * , .a best* use end asbestos fox .c ity " " 3 sbestosi and products containing asbestos h bMn misled and confused by d l* _ #^ ru)05 and regulation#. ^ l o l j r n r ^ ^ ' s o f i r ' adveriising have even contained n isloadln; or In - oeplete Information. ' I t is an accepted fa c t t ^ ^ s! ^ ; r ^ 5 \ r a l a l K s t S l s l ^ l t s % o r - ause disabling lung damage, coTM" " * ' . _XC9SS occurrences of bronchogenic T i o note th at a s b e s to ^ a n d s ta tis t leal ^ , in arcinoma, the two most common asbestos .bastes dust. The ris k of th is markers with massive, n ^ u ^ e T C a s b e s t L mines and m ills , manufacturing :pe exposure Is normally lim ited toasnesro ^ cons+ructton jobs using sprayed * carcinogenic condition* - ,M r " , "r , ` i5 * 5KrBS There is ^ ,W, no evidence that the 2:iMK.u-si-- - - FeasibUltv s! Nattonal^cadell^f Science of Air * " < * S '` numbers of fib e rs found |ty" general popuI+ * n . ^ 9d^ ^ def i n 11 !on and control o f man- This does not, however, preclude +* There are several varie tie s of rrr;i"~.'C*>*">-''- ^ r"r,iv made asbestos emiss ons I n t o t h a t some are more harmful than found cancer of the pleura. Asbestos Is a commercial r ^ ^ J eTM ,'icatel! ^ T T i r e fibrous and can occurring minerals that are bydra eP.TMJa } , 89rs. The S|X varieties are divided W **TM * *% be separated Into relatively s ft, . Ih)[, based on crystal structure. Into two classes, t h e s e r ^ t l n e class and the amphlboles Include w . . . . . . . i - m- 1 O r , ,, , n . b , fa r . oaf ora than 95 of -o rld f>' du' ; ^ "a Q T ,T Z r- , | w ot coaaarelal Importance are ' J t C v m . ; attained fr o . M r . - M . l - * ... .rr cement pipe. Amoslte Is used In insulating ano pa ^ p)astics> phylllte Is used primarily as a chem cal J1l8* * a ,Br9, 9t and most common Include: Chrysot11e Is used In over 3000 8pp' lc8^ s piper, fric tio n materials and asbestos-cement products, flo o r t l t e , usoesros PP . S s fe ts . te x tile s , plastics, and Insulation. T r . Incraaala, , M * * " " * "" stringently controlled thin chryaotlla. Some data Indicate that tv m r*la~ t j v* l L S 0[ ! **:* *> ** amphlbola minmis can result In te * development otiwaothe Homes. A penal of tpnrts In B ritain cone luted t t e t othor typeaof tlOnr Hmld lu* substitut* tor c ro cld o llt* whatever possible. The use'of' crocldolit in P -ita ln Ms been severely ro s trlc te T s lo c . I9TC eM ite iSportttlo n Into the united States and Japan has steediiy decreased tin e * t M M iddle ,, h* r's is * strong s ta tis tic a l relationship between mesothelioma and th* Inhalation of asbestos, crocldallt# and amosite Mva baan Involwad either alon or In combination. This Is tha casa In cro cld o lit* miners, asbestos wslng Insulation workers, asbostos tex tI la manufacturing, and in a large asbestos products manufacturing plant. U ntil recently the Insulation trade used (iwrt M osfto than chrysotle and large amounts of crocldolita Mara usad In England. The Insulation manufacturer 1$ also exposed to s ilic a and othar piMwwconiosis producing dusts, as well as additional agents and materials In the particular work environment. These coexisting agents, such as coal ta r and aromatic hydrocarbons, have bean Ignored In the reported studies of Insulation and other workers. When asbestos exposure has been limited to the serpentine class Cchryso- ?? l n `?u?boc sbestos workers, there Is strong evidence that no excess mesotheliomas w ill occur. Additional data, as reported by Dr. J, C. McDonald, show that the Quebec miners have no cess of lung cancer unless they were very heavily exposed (probably to greater than ID fibers per cc for forty years!. Dr. McDonald Is Professor of Epidemiology at McGill University In Montreal and has specialized in epidemiology for 25 years. The hi I Uams-Stelger Occupational Safety and Health Act of 1970 became effective on April 28, 1971. Based on congressional mall this law has stirred up more confusion and controversy than any other recent legislation. In softe of the nterest I t Is estimated that 30* of the nation's employers are not aware ot the law s existence and many others have no real Idea of what I t Is a lt about. Tha Congressional purpose of the Act is: "to assure so far as poss.ble every working men and woman In the Nation safe and healthful working conditions *nd to preserve our human resources." m cuJh -u l stai>' ishe<1 the Occupational Safety and Health Administration CuSmJ Within the Department of Labor, which has responsibility for adminis tration and enforcement. Research and related functions are handled by the Department of Health, Education and Welfare (HEW) through tha newly creeted National In stitu te ot Occupational Safety and Health (NIQSH). Five ml 11Ion employers and 60 m ill Ion of the nation' s 80 m ill Ion workers are covered by 0SHA, Specifically oxeludod from coverage are government em ployees and operations, such os mining, which are protected under other Federal health and safety laws. M*st of the controversy o rig in a lly surrounding OSMA was related to rules and the safety-oriented target Industries program. Early effo rts aimed at eliminating hazards In the five Industries whose safety record especially bad: Ungshoring Meat and Meat Product Lumber and wood Products ID safety were was I'Home S3*0Sir Transportation 6q*ilp*^nt in a nw t rat nose Issued January 4 , 1972, OSHA announced a T*rg* t ttourm 1 parallel the Target Induatrlee Program. The pragn* 1 S I t i iecK rs e la te d with lv k *t. c *> he < * of in itia l * " " r1* torts by OSHA ana NIOSMs ASbeSTOS Cotton Dust S ilica Usd Carbon Monoxide S S m . " r t * ia " i L ! 1 1 S - originally Conference of GovernmentaI Industrial Myglanlsts action was proi^tedby an A f ^ ^ r o ^ a s t bas^^r ^ S S .'w S - r ' I f in s Iu tfo T * e, tabUsh * ,rgency tem- ^ J 2 r ! 5 E S E . P * l >- " ' T " ' Ra9iS" here I t Is found that employees ere exposed to a2ii.32J3 * Continuing fron the OSHA news release, folioIng Is a summary of the spe c if ic s on th e f i v e target substances: Fm nlnuM , Substance Asbestos Can Produce Asbestos Is, Cancer At Risk 200,000 Industries Insulation, Ship building, construc tion, etc. Cotton Dust Bysslnosls 800,000 Cotton Process ing oi I types Silica S I I Icosls 1,100,000 Abrasives, mineral processing, sand blasting, etc. Lead Carbon Monoxide Severe nervous system dlsabi1Itle s Brain damage, death 1,600,000 Uncountable Thousands Ammunition, paint, battery, auto, etc. Metal processing, users of gaso Iinepowered equipment b ,s,rz chamlfcals are unknown. ssst\- - A new Standard for Exposure to Asbestos Dust w P ^ ' ^ * d ln the Federal Register, Volume 37, No. HO on hednosday. June 7 97Z. Tha J ! 5 1974. A peak concantratlon of 10 flbars par cc Is not to be *xIt ceeded at any time. AH at the fib er concentration* are those to which *ti ana* ployhe may ho exposed without protective clothing or equipment. The fir s t haste requirement of tha now standard is monitoring to determine whether or not flb ar ooncantrotions ara in excess of the exposuro lim its . This wa* to hava baan completed within s i* months at "ovary place of esipI^fynsebt where asbastos flb ar* ara released". Obviously thara are not enough industrial hygienists to anabla oompHanca with this provision. Some asbestos suppliers proved a monitoring service to customers and several insurance companies. have ptrsomnel trelnad In fib er counting. Many service companies have baan fonsed and 5nexperience has resulted In several Instances of Inaccurate and misleading results. NIOSH sponsors training schools and each session is f ille d to capacity. improper in te rp re ta tio n o t the regulations has created many misconceptions about the equipment and procedures needed to use asbestos. I f exposure lim its are not exceeded, there ere no fu rth e r compliance requirements except fo r medical examinations. Interpreted l i t o r a l l y , medical examinations are required fo r a ll employees in any "occupation exposed to airborne concentrations o f asbestos fib e r s " . Some d e fin itio n o f "exposed" is necessary since evidence indicates thet small amounts of asbestos fib e r have existed in the atmosphere fo r m illio n s o f years. The source o f these fib e rs would bo from the weathering of n a tu ra lly occurring surface outcrops. In its c r it e r ia document on asbestos, MiOSH recommended th a t "exposed to asbestos" be defined as "average exposures above one fib e r per cc or peak exposures above fiv e fib e rs per ec". Respirators and special c lo th in g are required in the construction trad fo r the spray a p p lica tio n of In sula tion and fire p ro o fin g m aterials, and fo r the removal of such m ate ria ls. This special p ro tectio n is not required fo r any other use of asbestos unless exposure lim its are exceeded. This Is also tru e fo r other Items such as s p e c ia lly equipped to o ls , product lim ita tio n s , change rooms, clothes laundering and waste disposal. Caution labels are required on products containing asbestos except where the fib e rs have been modified by a bonding agent or other materiaV"to prevent dusting during any normal subsequent use or handling. Besides raw asbestos fib e r , products which require package labeling would Include: dry acoustical spray products and jo in t cements, unsaturated roofing f e l t and te x tile s , various Insulating products made w ithout adequate binders. The labeling of a product does not p ro h ib it Its use. A! -hough the l i s t could be endless, products containing up to 40$ asbestos and not req uirin g a label could Include: reinforced p la s tic s (phenolic, nylon, polypropylene, polyester, e tc .) , roofing compounds, flo o r t i l e , reinforced rubber, reapy-mix jo in t cements, flo o rin g , coating and adhesives (po lye ste r, epoxy, urethane, casein, e tc .) , paint (PVC, elkyd, a c ry lic la te x ), mineral board, lubricants and greases. Soon a fte r the asbestos standards were published, Industry and SNA rep resentatives met to c la r if y a number of points w ith regard to In te rp re ta tio n and1enforcement. Since those are the f i r s t set of standards I t is expected th a t they w ill become guidelines fo r the other substances lis te d as ta rg et health hazards. There are several areas where lit e r a l In te rp re ta tio n Is ob viously not fe a sib le . I t was the consensus of the industry group a fte r the meeting w ith OSHA th a t enforcement and c ita tio n s would be reasonable provided th a t there was no attempt by Industry to circumvent the s p ir i t and in te n t of the 32 regulations or to compromise ttw safety ot the worker. In addition to the QSMA standards, thoro oro other regulatloiw mcornfng asbestos which oro being considered or which howo boon promutgeted. hi though expected six months oar I lo r, aa of tho and ot 1972 the Environmental Protection Agency tEPAJ had not Issued asbestos stondarda. Tho EPA was founded by tho Claan A ir Act of 1970 to improve tho environ nont to which tho general public Is exposed. On March 31, 1971, asbestos, along with beryllium and mercury, was identified as a "hazardous a ir polluntant" by Mr. Nil lien Ruckmlshaus, Administrator of the EPA. Whereas OSHA Is respon sible for ttw protection of workers, the EPA regulations w ill be designed to protect the general public from harmful emissions which may be generated by plants and other Industrial operations. In addition to requiring f ilt e r s on certain plant ventilation equipment, I t is expected that the spraying of certain materials w ill be prohibited. At this writing I t Is understood that the spray ing on structures of fireproofing compounds containing more than 1$ asbestos will be prohibited. This prohibition w ill not apply to Insulating materials, roof coatings, auto undercoating, decorative paints and coatings, and similar products containing asbestos held with a suitable binder. At least two states and local authorities have enacted ''asbestos" regula tions. Quoting from the New York State regulations: "No person shall engage in or allow surface coating by tho spraying of asbestos or asbestos - contain ing materials". The Intent wes probably to re s tric t the spraying of Insula tion and fireproofing materials on structures, sim ilar to the EPA provision, but a lite ra l Interpretation would eliminate many safe and necessary uses of asbestos. Apparently much more thought and expert advice went into regulations en acted by the State of Illin o is as they are feasible and workable without com promising public safety. However, tho law enacted by the City of Chicago is similar to that of the State of New York whlcu leaves much to be desired with regard to industry compliance and public safety. I t Is assumed that the EPA regulations w ill eventually be adopted or used as a pattern by state and local governments. Some proposed regulations are obvlou ly based on misleading articles about asbestos. Within the past year a rticle s ha'<e been published about the hazard from asbestos in fric tio n materials and to mechanics who blow dust from brake assemblies. The U.S. Public Health Service conducted a study which showed that less than l< of the 40-50J asbestos In brake linings remains as free fiber a fter wear. The asbestos Is converted by the high heat of fric tio n to a non-ttbrous, non-toxic material called fo rs te rlte . A study In England found that mechanics engaged in this a ctiv ity had TWA exposures of 0.68 fibers per cc of a ir , much less than OSHA' s 1976 standard. Thore Is no known study which Indicates any hazard to men employed in this occupation. In another a rtlc ie , Dr. Irving Solikoff of Mount Sinai Hospital was quoted as predicting 95,000 deaths from asbestos - related cancer among 250,000 men currenkly employed In the U.S. asbestos Industry. The two studies on which this dire prediction was based were of men employed In the Industry for a minimum of 20 years during the 1930's and 1940's whan dust levels were unfortunately many times higher than they are today. It Is Illo g ic a l to apply death rates re sulting from long term exposure to dust levels existing some 30 years ago to today's working population. 33 Quetlna if** *n ftle i# In IN dun* 1, 1*72 lesu* f tN W ill ltr a * t M em l * % m #f #** * Iff f lit * far bevere## iwhlna N v t Nan N *N 1 #Iff# *nd banr. far lnt*ee, *N eeuld N dang# I swal lowed", A itedy in great Irlta l *Nw*d that IN tat#I ateownf of u N t o i fiber fN In iritid ff N tr added up fa only 0.002 ounces In the total annual product lew of ewer mm bIMIfffl fallens, Thla 1 miuiIvaieanf te about Mu# parts par alllloff- MlIon by eight. Thor* la not on* shred of evidence tN t lng*stlg auh #H amount of aboatai Is Niardous. Matty a la rlo re fe r fa Or. $ # II N f f ana his stud I as a t Mount binol Mo*p*t#lI t N ulo i nota# th a t whan Or, Sell ke ff use* th# term H*abstci w erN rs* ho Is eat re fe rrin g to th * wan tngagad In t N ooiwral asboatoa mining, I I lin g or manufaetaring Indwatftos. MU stu d Ia haw# turan an man employ*# only In t N essesto* ln#ula ta n traa oho belong te a union e a ll*d tha "Maat, Prest t nalatan and Aspeato* Wofhers", eewajflly re fe rre d ta aa th# asbestos workers unan, I t wes reported In an* Meunt HI nal survey th a t th a r* was only on# dust count tabn fo r ovary #0,000 mand*y* worked by 5M0O "esbestee workers", they hove reported *m s im ila r dust count frequencies fo r years, but elweys In rater** ta tho construction Industry, novar to asbestos m illin g end manotee turlfffli plants. Oust aunts hove been toben an a regular basis In meat asbestos operations for years, w ith nee and b ettor taunting techniques, pel le tlto d asbestos, oof processing, and Ipreved operating co nditions, many Industries ere fin d in g that OTrtA compilan* presents no major problem, In many ases dusty conditions are being caused By other raw mater ta le , The new membrane f i l t e r technique u-r taunting, asbestos fib e rs precludes the Inclusion of many dust partieses as asbestos, th# problem becomes one of nuisance dust control not a lengthy and usually unnecessary program to " get r id ot asbestos". One serge c h ry s a tll# asbestos user is :,* receiving pel le t I ted asbestos In bulb hopper cars eon ta lnlng about W ton of product, With appropriate storage, tra n s fe r, and vo n tn a tio n equipment, there Is ^ a s b e s to s dust released to the work or public atmosphere, tha asbestos p e lle ts flow fre e ly from the car end there Is no residual m ate ria l, f l a s i k bags and repul pable paper bags ere other means used to preclude container opening by personnel, More Is probably known about the pote ntia l health hazards of asbestos and the proper means for c o n tro llin g or e lim in a tin g them than would be the case w ith possible su b stitu te m aterials. I t would be Imprudent to use unproven m aterials, whose health e ffe c ts are unknown, to replace asbestos which has proven Its use* fulness fo r the past i 00 years. Asbestos Is used by the p la s tic s industry fo r reinforcement, heat re s ts " tanca and flow eon fro I , About M# of the 290,(500 tons used annually Is c h ry s e tlle , normally dioses fo r most a pp lle nt Ions because of its p le n tifu l supply any product u n ifo rm ity, Sometimes the special advantage at another fib e r ere required. Polypropylene has been reinforced w ith anthephylI He asbestos because i f permits w ire e ffe c tiv e heat s ta b iIiM tio n . Mecenf work may overee# th is short remlug of W y s e f I Is end permit Its use In th is large a p p lic a tio n . C h ry s o tlls also has poor resstanse lo Ids end an amphlbele Is usually hoeon fo r th is type ppiteat Ion, C hrysotlie 1 sat apart from the amphlbele m ineral* by Its p a s ltlu * surface charge, softness, f l M i b l l l t y , and tow re fra c tiv a Indas, It f i b r i l di amatar I 94 le ss Mm 0.05 m icron, Mi smallest among conmonly known flb o r s , 0 I t has exceptional mechenlcel strength. Wot processing o f chryaotllo ha* permitted chsmlcelly modified product* with surface properties sim ila r to pyrofl* s ilic a to r use In ant tang and thixotropic applications. Compered to ch ryso tlle , anphlboie fibers ara larger In cross-section, harsh, and hare, they are a n io n ic In surface charge and sore resistant to acids. The unit chrysotlla f ib r il Is now recognized as a naturally occurring reinforcing whisker. Bacausa of Its high strangth, stlffnass and aspect ra tio It provides excellent whisker reinforcement; assuming that I t has a high degree of fiber liberation and has baen specially processed to remove extraneous gangue m aterial. The largest uses for esbestos In plastics are In vinyl asbestos floor t i l e and In phenolic molding compounds. It Is also used In numerous other compounds of polypropylene, polyester, nylon, melamine, epoxy, silicone, etc. It Is used In many product types such as fric tio n materials, heat resistant and electrical components, sealants, adhesives, coatings, mastics, etc. Asbestos has been, is, and can be used safely in the plastics Industry as well as most other areas of application. I t Is an Important and necessary raw material and its use cannot and should not be prohibited. Medical, industrial and governmental personnel must continue to work together to estab lish reasonable exposure lim its while, a t the same time, providing safe work areas for employees.